Globally Harmonized System (GHS)
Labeling Requirements

Overview

The Globally Harmonized System (GHS) is an international system that the United Nations created for the unified classification and labeling of chemicals. It was officially adopted in the U.S. on March 26, 2012, by the Occupational Safety and Health Administration (OSHA). OSHA's adoption of the GHS is actually a revision of the Hazard Communication Standard designed to align with the GHS. It's called HazCom 2012.

A written HazCom plan that documents and outlines how your company responds to hazardous chemicals is required in order to comply with OSHA's 29 CFR 1910.1200(e) regulation for Hazard Communication. Tracking, maintaining and managing your chemical inventory is crucial to your HazCom plan and GHS compliance. In order to maintain a successful plan, you must keep your inventory organized and updated.

Update chemical containers with GHS labels

Labeling is the cornerstone of GHS compliance. With an emphasis on consistency and comprehension of chemical labels, it is important to know what goes into a GHS label for primary and secondary containers. There are six key elements to a GHS label that you need to know.

The Six Elements of a GHS Label

Signal Word.

The signal word indicates hazard level. "Danger" is used for the most severe instances, while "Warning" is less severe.

2

GHS Symbols (Hazard Pictograms).

These pictograms are used to identify hazardous products and are commonly grouped by chemical/physical risk, health risk and environmental risk.View our GHS pictogram guide

3

Manufacturer Information.

This identifies the manufacturer's company name, address and telephone number.

4

Precautionary Statements/First Aid.

These are phrases that are tied to each hazard statement. They describe general preventative, response, storage or disposal precautions. These statements are found on the chemical's Safety Data Sheet. Similar to Hazard Statements, Precautionary Statements can be identified by a P-Code (like P100).

5

Hazard Statements.

These are phrases that describe the nature of hazardous products and the degree of hazard. Hazard statements are on the chemical's Safety Data Sheet (SDS) and identified by an H-Code (like H100).

6

Product Name or Identifiers.

This identifies the product or chemical name. Additional identifiers can be noted to the right of the Manufacturer's information (#1).

Primary vs. Secondary Containers

Primary Container Labeling

Primary chemical containers are the bags, barrels, bottles, boxes, cans, cylinders and drums that you receive from the manufacturer. These containers should be labeled following the GHS mandates per the GHS label example above and include all six labeling elements.

When a label is on a container directly from a supplier, this label cannot be removed, altered or defaced. If it needs to be replaced, the new label must contain the same information as the original.

Secondary Container Labeling

Secondary containers are usually smaller than primary containers and could include spray bottles, jugs, or jars. These containers usually hold chemicals that are transferred from a primary container. Secondary containers must comply with GHS labeling requirements except when the following criteria are met:

The material is used within the work shift of the individual who makes the transfer

The worker who made the transfer is in the work area the entire time during use

The container stays within the work area and in the possession of the worker who filled the container

OSHA has not changed the general requirements for secondary container labeling specifically. Employers have the option to create their own workplace labels by using all of the information provided by the manufacturer or using a combination of the elements in the GHS label example above specific to the hazards of the chemicals.

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